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June 2026

Insolvency – Real estate projects – Project-wise resolution – Homebuyers’ interests – CIRP can proceed project-wise. [Insolvency and Bankruptcy Code, 2016]

By Dr K. Shivaram, Senior Advocate, Rahul K. Hakani | Shashi Bekal, Advocates
Reading Time 2 mins

13. Alpha Corp Development Pvt. Ltd. v. Greater Noida Industrial Development Authority & Ors.

2026 INSC 449

Insolvency – Real estate projects – Project-wise resolution – Homebuyers’ interests – CIRP can proceed project-wise. [Insolvency and Bankruptcy Code, 2016] 

FACTS

Corporate insolvency resolution proceedings were initiated against a real estate developer engaged in the development of multiple housing and commercial projects. Certain projects were developed on lands leased from the Greater Noida Industrial Development Authority (GNIDA), while one project was situated on freehold land unconnected with GNIDA.

Separate resolution plans were approved by the NCLT in respect of different projects. GNIDA challenged the approvals before the NCLAT which set aside the orders passed by the NCLT.

Various stakeholders, including developers, homebuyers’ associations and project entities, approached the Supreme Court.

HELD

The Supreme Court recognised the principle that insolvency resolution in real estate matters may proceed on a project-wise basis rather than ne

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